Ministerial Decree no. 2025‑530 of October 3, 2025, published in the Journal de Monaco on November 14, 2025, updates the list of HRSTs.
Main changes to the list of High-Risk States or Territories (HRST):
The list now includes 31 States. 2 States have been added and 9 States have been removed from the list:
Afghanistan
Algeria
Angola
BarbadosBolivia
British Virgin Islands
Bulgaria
Burkina Faso
Cameroon
Democratic Republic of the Congo
CroatiaGibraltarHaiti
Islamic Republic of Iran
Ivory Coast
JamaicaKenya
Democratic People’s Republic of Korea
Lao People’s Democratic Republic
Lebanon
Mali
Mozambique
Myanmar/Burma
Namibia
Nepal
Nigeria
UgandaPanamaPhilippinesSenegalSouth Africa
South Sudan
Syria
Tanzania
Republic of Trinidad and Tobago
United Arab EmiratesVanuatu
Venezuela
Vietnam
Yemen
As a reminder, the obligations relating to HRSTs are as follows:
When a transaction involves a counterparty with links to an HRST, a “examen particulier” report must be drawn up and kept (cf. article 14 of law no. 1.362 as amended);
When a business relationship or transaction involves an HRST, enhanced due diligence measures must be put in place (cf. article 14-2 of law no. 1.362 as amended).
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